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Is Your Safety Incentive Program Illegal Under OSHA?

The Bureau of Labor Statistics in the United States recorded that 2.8 million workplace injuries occurred in 2015, more than half of which resulted in time away from the job. The cost to business? According to the CDC, workplace injuries (and the affected employees’ subsequent absences) amount to well over $200 billion per year.

One would assume that having a safety incentive program in place would reduce the prevalence of injuries on the job, but, in fact, the traditional approach to such programs has proven otherwise—and the Occupational Safety and Health Administration (OSHA) has gone to great lengths to regulate and improve these programs for companies and their employees across the country.

What went wrong with the traditional safety incentive program?

Many non-compliant safety incentive programs are based on lagging indicators; that is, success is built upon past activities and events that dictate that a company is headed in the right direction where safety is concerned. Lagging indicators include:

  • The frequency and/or severity of injuries
  • The amount of lost work days
  • The number of citations from OSHA
  • The amount lost in workers’ compensation claims

All of this is valuable data to have, of course. But the problem is not in the data. The problem is that companies give incentives for a reduction in the numbers themselves—fewer injuries mean more rewards. For example, a number of companies give cash bonuses or gift cards to their employees for having injury-free months or quarters. As such, individual employees are incentivized to not report on their injuries, while companies push to keep unsafe conditions under wraps for fear of OSHA citations.

Some companies even go so far as to threaten or punish those employees who file reports on unsafe practices, their own injuries, or the injuries of others. In one particularly stunning case, if a worker reported an injury, he would be forced to wear an orange vest for a week, making it obvious to his coworkers that the reporting of the injury had denied them their expected prize for the month (therefore making him, for all intents and purposes, a pariah among his coworkers).

“An employer cannot retaliate by taking ‘adverse action’ against workers who report injuries, safety concerns, or other protected activity.”
The Whistleblower Protection Programs, OSHA

What data should be used for our OSHA-compliant safety program?

Safety incentive programs miss the mark with OSHA when they rely solely on lagging data—data from things that have already happened. Instead, success KPIs should be based on leading indicators instead. Leading indicators, in the context of workplace safety, can help predict where improvements will be made if particular actions are taken.

These include, but are not limited to:

  • Training programs conducted by the company for its employees
  • Safety certifications received by a particular individual, team or company
  • Employee surveys and risk assessments
  • New safety procedures policies

What are the benefits to an OSHA-compliant safety incentive program?

If done correctly, implementing a safety incentive program at your company has a number of benefits. It is, effectively, the final piece of your workplace safety initiatives puzzle, incentivizing employees
and management to make continual improvements to all of the other areas.

Your OSHA-compliant safety incentive program can:

  • Identify potential issues by encouraging employees to report unsafe conditions or possible hazards in order to avoid future accidents.
  • Educate employees on proper procedures by keeping them up-to-date on the latest policies with posted content and online training.
  • Reinforce safe behavior with rewards, using both monetary and non-monetary incentives to encourage participation and reward those who work to improve the safety of the working environment. OSHA even suggests that “throwing a recognition party at the successful completion of company-wide safety and health training” as a reward idea.
  • Drive employee engagement with increased awareness and an interest in the common goal of keeping their place of employment a safe place to work. In fact, a recent Gallup study showed that the top 25% of engaged companies see 70% fewer safety incidents than companies that are not engaged.

Effective January 1, 2017, OSHA’s “final rule” on workplace injuries will require the full automatic disclosure of all workplace injuries at certain companies to store in its central database. And, yes, these details will be public. Additionally, the rule will no longer require an employee to file a complaint about their employer before the agency can get involved; now, OSHA can cite companies for retaliation against employees based on its own evidence of such activities. Combining these two factors, OSHA hopes companies will be pressured to boost their workplace safety practices.

Now is the time to examine your existing safety incentive program to determine if a) it is compliant with OSHA’s rules, and b) it is set up in such a way that you see continuous improvements.

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